- 11 -
failed to provide evidence upon which we can make a rational
estimate. See Vanicek v. Commissioner, supra. We sustain
respondent’s determination on this issue.
3. Legal and Professional Fees
Petitioners deducted $73,232 in 1990, $42,228 in 1991, and
$33,733 in 1993 for legal fees. Generally, legal fees may be
deductible under section 162(a) if they are connected to a
taxpayer’s trade or business. See Guill v. Commissioner, 112
T.C. 325, 328-329 (1999); Davis v. Commissioner, T.C. Memo. 1999-
250.
Petitioner generally testified that he incurred more than
$32,000 in legal fees in connection with his consulting work for
the Federal Reserve Board. Petitioner did not provide any
additional details regarding the legal fees, such as the dates,
attorneys retained, and how the legal expenses were incurred in
his trade or business.9 Petitioner also did not produce
documents at trial to establish that he incurred these expenses.
We are unable to estimate an amount for legal fees because
petitioner failed to provide evidence upon which we can make a
rational estimate. See Vanicek v. Commissioner, supra. We hold
for respondent on this issue.
9 Petitioner’s testimony as to the legal fees was so
vague that we do not know the year or years in which petitioner
incurred the $32,000.
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